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Privacy Policy

Table of Contents

  1. Introduction
  2. Personal data which we collect about you
  3. How we collect your personal data
  4. How we use your personal data
  5. Explaining the legal bases we rely on to process personal data
  6. Advertising, marketing and your communications preferences
  7. Cookies
  8. Disclosures of your personal data
  9. Payment information
  10. Data security
  11. Third-party links
  12. Your legal rights
  13. International transfers
  14. Changes to this privacy policy

 

1. Introduction

This privacy policy tells you how the THANC (Thyroid, Head and Neck Cancer) Foundation uses your personal data when you visit our website, resources or make donations to support our mission.

It also tells you about your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data.

This privacy policy was last updated on May 25, 2018 and historic versions can be obtained by contacting us.

If you have any questions, or would like to exercise your privacy rights, please follow the instructions in this privacy policy. See how to contact us about privacy below.

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    How to contact THANC about privacy

    If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at dataprivacyofficer@thancfoundation.org or write to us with your letter addressed to: Data Privacy Manager, THANC Foundation, PO Box 1021, New York NY 10276 USA.

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can do this by updating your account or contacting us at info@thancfoundation.org. Thank you.

    Our Website

    Our website provides information and resources about the THANC Foundation and our work to fulfil our nonprofit mission. This website is not intended for children and we do not knowingly collect data relating to children.

    The THANC Foundation is the data controller responsible for this website and any handling of personal data carried out by or on behalf of the THANC Foundation.

 

2. Personal data which we collect about you

We collect personal data, identity data, contact data, financial data, transaction data, profile data, technical data, usage data, tracking data, and marketing & communications data.

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    Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    We collect a variety of information about our friends and donors.

    Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.

    Contact Data includes mailing address, email address and telephone numbers.

    Financial Data includes donation details whether this is by check, wire transfer, stock transfer or credit card payment. This information is not stored and is destroyed once a donation of any type is made.

    Transaction Data includes details about donations from you to THANC.

    Profile Data includes any profile you have created by registering on our site, your username and password, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).

    Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

    Usage Data includes information about how you use our website, products and services.

    Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as Hotjar or mobile identifiers.

    Marketing and Communications Data includes your preferences in receiving communications from us.

 

3. How we collect your personal data

We use different methods to collect data from and about you including direct interactions and automated technologies or interactions.

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    Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or through chat or social media.

    This includes personal data you provide when you:

    • sign up to receive the THANC Foundation newsletter;
    • make enquiries or request information to be sent to you;
    • create an account on our website;
    • engage with us on social media; or
    • contact our office for any reason

    Automated technologies or interactions. As you interact with us, on our website or via social media, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website or resources.

 

4. How we use your personal data

We will only use your personal data when the law allows us to.

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    How we use your personal data

    We will only use your personal data when the law allows us to.

    Most commonly, we will use your personal data in the following circumstances:

    • Where you have consented for us to contact you.
    • Where it is necessary to provide you with the [services] you have requested or to enter into a contract.
    • Where it is necessary for our contract performance (for example to process a donation made to THANC by you) and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal or regulatory obligation. For example, keeping records of our donations as part of our annual audit and IRS 990 reporting obligations.

    Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time. If you do not permit us to use your personal data, we may not be able to provide you with updates on head and neck cancer research, invite you to support groups or events, or allow you to participate in our programs [etc.]

    See Explaining the legal bases we rely on to process personal data to find out more about the types of lawful basis that we will rely on to process your personal data. 

 

5. Explaining the legal bases we rely on to process personal data

The table below shows you a description of all the ways we plan to use personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

    We do not carry out any automated decision making.

    If you ever have any questions about this, all you have to do is ask. See how to contact THANC about privacy below.

 

6. Advertising, marketing and your communications preferences

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what events or programs we think you may be interested in. This is how we decide which products, services and offers may be relevant for you and tell you about them. This is what we call direct marketing.

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    We may carry out direct marketing by email, phone, text or post. For example, you might have the Intouch newsletter hit your inbox or your mailbox.

    On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up to receive InTouch or as part of creating an account or making a donation – and you have a right at any time to change your mind and say no thank you and opt out. The easiest way to opt out is to use the unsubscribe link at the bottom of the communication.

    We have established a privacy center where you can view and make certain decisions about your personal data use www.thancfoundation.org/manage-your-consent 

    You may learn about THANC Foundation programs and events in different ways and not all of these are based on using personal data. There are some things we may do that may be specifically directed at you:

    • emails, for example the InTouch Newsletter, annual report and event invitations
    • text messages, for example with reminders
    • newsletters or solicitations by mail, or
    • phone calls, to tell you something that might be relevant or of interest to you

    Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you.

    Cookies can also tell us if you have seen specific information, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our information and control the number of times people might be shown an invitation or request for funding. Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.

    If you want more information about Tracking Data, in particular cookies, see Cookies below.

 

7. Cookies

You can see from Advertising, marketing and your communications preferences above, that cookies are a tool which we (and everyone one else who operates online) uses for advertising. That is just part of why cookies are used.

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    Cookies help THANC to be more effective and provide help in the background to make the process of being our supporter easier.

    Other cookies collect information about how visitors use our resources, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how our website and resources work.

    There are also cookies that allow us to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.

    There are cookies that collect information about your browsing habits in order to make information delivered to you more relevant to you and your interests (see Advertising, marketing and your communications preferences above).

    When you use thancfoundation.org or our affiliated resources, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It’s important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 

8. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it.

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    We may share personal data with the following categories third parties:

    • Service providers (such as technology service providers, payment processing and fraud prevention providers);
    • auditors and professional advisers like bankers, lawyers, accountants and insurers; and
    • government, regulators and law enforcement.

    We do not share personal data other than as listed above. However, when information is shared as indicated above, we require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

9. Payment information

THANC uses third party payment processors Transactiv and PayPal to process payments made for donations via the Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them.

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    Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors. Unless you call us to make a credit card donation by phone, THANC never sees your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page.

    For PayPal we only store the tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal.

 

10. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

11. Third-party links

This website may include links to third-party websites, plug-ins and applications (for example, the ability to sign in with Facebook). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

12. Your legal rights

Because your privacy and the security of your data is important to us, we have aligned our practices with the robust and protective requirements under the EU General Data Protection Regulation (GDPR). You have certain rights under data protection laws in relation to your personal data.

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    Your rights may include:

    • The right to be informed – the obligation on us to inform you how we use your personal data which is handled via this privacy policy;
    • The right of access – the right to request a copy of the personal data we hold about you;
    • The right to rectification – the right to make us correct personal data about you that may be incomplete or inaccurate;
    • The right to erasure – the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
    • The right to restrict processing – the right for you in certain circumstances to ask us to suspend processing personal data;
    • The right to data portability – the right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
    • The right to object – the right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
    • Rights in relation to automated decision making and profiling

    These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.

    If you wish to exercise any of the rights set out above, please contact us at privacy.info@thancfoundation.org 

    You will not have to pay a fee to access your personal data or to exercise any of the other rights as listed above unless your request is clearly unfounded, repetitive or excessive in which case we may require a nominal fee to cover our costs. Alternatively, we may refuse to comply with your request in these circumstances.

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    We will respond to all legitimate requests within 30 days. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

    We have appointed a data privacy officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy officer using the details in How to contact THANC about privacy below.

    You have the right to make a complaint at any time to a supervisory authority [such as the Information Commissioner’s Office (“ICO”) in the UK (www.ico.org.uk)]. We do hope, however, that you will contact us first so that we may do everything possible to correct the situation.

 

13. International transfers

The THANC Foundation has a global mission and it, or its service providers, may process, transfer, and store information about our users on servers located in a number of countries outside the European Economic Area (EEA), including in the United States. Since we are committed to protecting your information, we take steps to ensure that there are appropriate safeguards in place when we transfer that data.

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    Your data will be transferred to the United States. Data protection laws may be less stringent than in your country. To ensure that your data is adequately protected, we transfer your data subject to suitable safeguards being in place.

    To find out more about how we safeguard your information (including obtaining a copy of such safeguards), please contact us at dataprivacyofficer@thancfoundation.org.

 

14. Changes to this privacy policy

The General Data Protection Regulation is new and supervisory authorities are still issuing additional information on how organizations should follow the new regulations. For this reason, you may see updates to this privacy policy over the coming months.

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